23 comments
Current DEQ regulations have split the State into Solid Waste Planning Districts, with a 20 year old recycling requirement of 25% for the large planning districts. Fairfax County has exceed the requirement in 19 out of the 20 years, currently we are at 46.5%. We have been stuck in the mid 40% for several years. Meaningful new programs to increase our recycling rate haven't been proposed in years.
The legislature should increase the recycling requirement for large planning districts to 80%, phased in over 7 years. There are municipalities that already achieve this, proving that this is doable. With a new goal to achieve, local municipalities will take the lead on introducing impactful recycling programs. Without a new goal, the recycling rate will continue to stagnate, as inivation is stifled.
Kitchen food scraps are a large percentage of our trash stream. Arlington County has started collecting residential food scraps in with the yard waste and sending everything to the existing commercial compost facility. This should be done with all large solid waste planning districts. But we should start to incorporate the large food scrap generators such as restaurants and grocery stores. Counties won't do this unless a new goal is implimented.
There are many examples of things we could be doing to increase our recycling, things other places are doing better than we are. But we don't have the incentive to change. Let's unleash the creative power to have Counties increase their recycling in the ways that they see best.
In Fort Worth, TX, a resident can get two compost pails for $20 from the city: one for the kitchen and a 5 gallon one for a week's worth of food scraps; and residents then take that, and any other waste that needs special handling eg batteries, old paint etc to one of many locations in this sprawling area. If this can be done here, we can re-invent cost effective, land conserving, less pollution ways to manage waste in Virginia.
Please pass legislation REQUIRING all jurisdictions to plan and enact capture of organic materials for composting, stop the burning of all plastics. Enact laws that require the recycling of all food grade glass back into food grade glass. We're squandering the resources we've been given.
Chapter 14. Virginia Waste Management Act 10.1-1411. Regional and local solid waste management plans B. states, “The Board’s regulations shall include all aspects of solid waste management including waste reduction, recycling and reuse, storage, treatment, and disposal and shall require that consideration be given to the handling of all types of nonhazardous solid waste generation in the region or locality.”
Chapter 14. Virginia Waste Management Act - 10.1-1411. Regional and local solid waste management plans. Which defines and lays out the criteria for the minimum 25/15 percent recycling rate, is not limited to only Municipal Solid Waste. It states, “The Board’s regulations shall include all aspects of solid waste management including waste reduction, recycling and reuse, storage, treatment, and disposal and shall require that consideration be given to the handling of all types of nonhazardous solid waste generation in the region or locality.”
We propose that the word municipal be removed from 9VAC20-130-120 B. Which would change it from, “A minimum recycling rate as specified in 10.1-1411 of the Code of Virginia for total municipal solid waste generated annually in each solid waste planning unit shall be met and maintained.
To “A minimum recycling rate as specified in 10.1-1411 of the Code of Virginia for total solid waste generated annually in each solid waste planning unit shall be met and maintained.
Removing municipal from the language incentivizes planning units to invest in and make the effort to recover and recycle material outside of MSW such as construction and demolition debris and electronic waste as these efforts can then be reported potentially providing a direct impact on their overall recycling and recovery numbers.
9VAC20-130-10. Definitions. We recommend the following:
“Principal recyclable materials” or “PRM” be expanded to include mattresses and box springs.
“Material Recovery Facility” be expanded to include “Construction and Demolition (CDD) Material Recovery Facility” with a definition stating, “a facility for the collection, processing and marketing of recyclable materials including concrete, brick, block, metal, wood, plastic, shingles, and drywall.
Gasification is a process that converts biomass- or fossil fuel-based carbonaceous materials into gases, including as the largest fractions: nitrogen (N2), carbon onoxide (CO), hydrogen (H2), and carbon dioxide (CO2). This is achieved by reacting the feedstock material at high temperatures (typically >700 °C), without combustion, via controlling the amount of oxygen and/or steam present in the reaction. The resulting gas mixture is called syngas (from synthesis gas) or producer gas and is itself a fuel due to the flammability of the H2 and CO of which the gas is largely composed. Power can be derived from the subsequent combustion of the resultant gas, and is considered to be a source of renewable energy if the gasified compounds were obtained from biomass feedstock.
Pyrolysis is one of the technologies available to convert biomass to an intermediate liquid product that can be refined to drop-in hydrocarbon biofuels, oxygenated fuel additives and petrochemical replacements. Pyrolysis is the heating of an organic material, such as biomass, in the absence of oxygen. Biomass pyrolysis is usually conducted at or above 500 °C, providing enough heat to deconstruct the strong bio-polymers mentioned above. Because no oxygen is present combustion does not occur, rather the biomass thermally decomposes into combustible gases and bio-char. Most of these combustible gases can be condensed into a combustible liquid, called pyrolysis oil (bio-oil), though there are some permanent gases (CO2, CO, H2, light hydrocarbons), some of which can be combusted to provide the heat for the process. Thus, pyrolysis of biomass produces three products: one liquid, bio-oil, one solid, bio-char and one gaseous, syngas. The proportion of these products depends on several factors including the composition of the feedstock and process parameters. However, all things being equal, the yield of bio-oil is optimized when the pyrolysis temperature is around 500 °C and the heating rate is high (1000 °C/s) fast pyrolysis conditions.
9VAC20-130-165. Recycling data reporting.
Rather than requiring reporting for planning units with a population of less than 100,000 to report every four years, we believe they should be required to report annually. The data is being collected in all the planning units annually already, and requiring the data to be reported annually will improve the quality of the data.
Gasification as defined ( in our previous comments)is an alternative method for waste management of MSW that is effective in high population areas with limited landfill space.
Pyrolysis is an effective method to deal with plastics 3-7, tires construction debris (Including wood, composites and other organics and other constituent materials in the waste stream
Green waste as diversion not recycling.
Consistency in planning and siting of compost facilities.
Under current regulations, Compost facilities are required to be held up to the same standards as landfills. We believe that Virginia needs to look at the standards required for compost facilities to allow for more to be built around the state.
I have lived in and have been a homeowner in Fairfax County for more than 50 years. I also spent most of my career as a consultant to the US EPA's Office of Solid Waste on recycling and sustainability. I deeply care about the County's recycling program and have seen it deteriorate over time. I think it's important to focus on the "big ticket" opportunities to divert materials from disposal, especially given that the Covanta WTE facility is aging. A big opportunity would be to divert the many tons of organic waste from the many grocery stores, schools, and restaurants in our county, by establishing a local industrial composting facility. The compost could be sold at a reasonable cost to subsidize some of the operation. It's a nice PR strategy to encourage residents to compost but that's really not going to make a big difference. Commercial composting will. I really hope this happens in my lifetime.
Virginia's solid waste and recycling regulations are unclear and lacking in ambition. Reducing waste is extremely important. The DEQ should first and foremost look at ways to incorporate source reduction into their regulations starting with the most littered as well as difficult to recycle products. The ultimate goal should be a truly circular economy and the plan should be in line with this mission.
Other recommendations:
Approximately 40 percent of the food produced in the United States goes uneaten. Much of this organic waste is disposed of in solid waste landfills, where its decomposition accounts for over 15% of our nation's emissions of methane. Jurisdictions that incinerate MSW emit roughly one ton of greenhouse gases for every ton of MSW. Food waste not recycled not only squanders natural resources, it also contributes to climate change.
Recognizing the importance of food scraps to our environment, I recommend that 9VAC 20 130-165 and DEQ form 50-30 be modified to require collection and resorting of food waste recycling, whether by composting, diversion to animal feed, anaerobic digestion or other means of segregating and recycling food waste from MSW streams.
9VAC 20 125, 120-165 and DEQ form 50-30 should be modified to encourage the prevention of food waste generation by commercial generators and residents, directing recovery of edible food from high volume commercial food waste generators, and ensuring that a significant portion of inedible food waste from large volume food waste generators is managed in a sustainable manner and does not end up sent to landfills or incinerators. All solid waste planning units should be required to report annually on the tonnage of food waste and other vegetative waste not otherwise reported as Yard Waste or Waste Wood on DEQ form 50-30 that is recycled. The report should summarize the amount of food scraps that are recycled.
The required recycling rate for larger solid waste planning units is 25%, for smaller units it is 15%. These rates are inadequate and should be set much higher, as much as 80% for larger units and 50% for smaller units. California's SB54 sets up extensive recycling and reduction rates. Maryland mandates 35% recycling for larger jurisdictions and 20% for smaller jurisdictions.https://www.rila.org/getmedia/2303cf37-d7d7-40f2-b4ae-41088067c9bf/Mandatory-Recycling-and-Disposal-Bans-Fact-Sheet-1-23.pdf?ext=.pdf
Modify credit for source waste reduction plans to require that jurisdictions that received 2% credits for source reduction plans in the previous 5 year plan must demonstrate actual reductions of 2% or more. Otherwise, simply having a plan that isn't carried out is not justifiable.
Jurisdictions should not receive recycling credit for contaminated recycling or unmarketable recycling that is rejected by the MRFs and landfilled or incinerated. DEQ Form 50-30 should be modified to require jurisdictions report the tonnage of recycled materials that are contaminated and rejected by MRFs, or otherwise landfilled or incinerated. That amount should be subtracted from the total recycling. A 2019 DEQ report "Recycling in Virginia: An evaluation of recycling rates and recommendations (Chapter 615, 2018 Acts of Assembly" estimated that 23% of recycling in Virginia is contaminated. Local planning units should not receive recycling credit for materials that are contaminated, rejected by the MRFs, and ultimately landfilled or incinerated. https://rga.lis.virginia.gov/Published/2019/SD7/PDF
Dear Waste Management Board,
We are writing in strong support of keeping the false solution of advanced recycling out of Virginia on behalf of Waterkeepers Chesapeake, a coalition of seventeen Waterkeepers, including three in Virginia, working to make the waters of the Chesapeake and Coastal Bays swimmable and fishable. Currently, recycling regulations in the Commonwealth fail to specifically exclude practices that convert plastic waste to fossil fuels from their recycling definitions. This allows advanced recycling facilities to contribute harmful pollutants to the environment, burden already vulnerable communities, and waste economic development funds under the guise of a false solution to solving the plastic pollution problem. Advanced recycling is inherently a polluting activity as studies conducted by plastic manufacturers revealed that advanced recycling generates more harmful emissions than either landfilling plastic or burning it and “generates far more pollution than eliminating single-use plastics altogether.”
At the federal level, the EPA’s recent Draft National Strategy to Prevent Plastic Pollution states that the federal agency does not consider “activities that convert non-hazardous solid waste to fuels or fuel substitutes (‘plastics-to-fuel’) or for energy production to be ‘recycling’ activities.” Virginia should not fall behind the slow-moving EPA as not only would Virginians’ health suffer but doing so prevents a true circular economy, which would turn plastic waste to new plastic products–not fuel, fuel ingredients, energy or other feedstock.These regulations should be reviewed with an eye towards improving Virginia’s environment and the health of its citizens, not guided by Executive Order 19 and its harmful stated goal of removing 25% of all regulatory requirements in the Commonwealth.
For these reasons stated above, we urge the Board to revise the recycling definitions in a way to best protect the health of Virginians and the Commonwealth’s unique and beautiful environment, and not guided by the harmful principles of Executive Order 19.
Sincerely,
Waterkeepers Chesapeake
Alex Villazon
Climate & Justice Legal Fellow
alex@waterkeeperschesapeake.org
Good afternoon,
I’m writing to reject efforts to encourage advanced recycling and instead use the taxpayers funds to increase education surrounding the reduction of the use of plastic.
Laura
The current solid waste planning and recycling regulations do not go far enough to adequately manage the plastic waste stream and protect Virginia's residents and environment. The regulations, emboldened by recent Executive Orders, enable and encourage the development and operations of advanced recycling facilities in Virginia. Advanced recycling and pyrolysis are false and flawed solutions to the plastic pollution crisis which threaten local environmental and community health. The goal of waste management and recycling should be to achieve a truly circular economy; not just burn or combust waste into fuel or fuel substitutes. Contrary to its greenwashed advertising, advanced recycling technology will not reduce the use of single-use plastics, but instead will incentivize their continued use as a feedstock for plastics-to-fuel facilities (VCN, 2022).
Additional comments:
Eleanor Kluegel
Clean Fairfax Council / Litter Free Virginia
There is no good option for disposing of waste. When we bury it, landfills leech toxins and emit methane gas. Burning trash, as is done in several Virginia jurisdictions, is damaging to our resources and is even more costly and polluting. Most often, our landfills and incinerators are located in communities of color. That’s why we need to reduce waste.
The minimum recycle requirement should be raised for large solid waste planning districts from the current 25% to 80%, phased in over several years. Fairfax County, where I live, has exceeded the state minimum recycling rate in 19 out of the past 20 years. But the County’s recycling rate has been stagnant in the mid-40s for several years. No new impactful programs have been enacted to increase our recycling.
80% diversion is achievable. We’ll need to add composting and glass collection, not only in residential areas, but in the vastly underserved multifamily housing and restaurants and grocery stores. We can continue to nibble away at our waste problems, or we can change the rules to allow large scale meaningful changes.
Other jurisdictions have set goals and are making progress. Gainesville, Florida’s goal is to divert 90% of waste by 2040. Dallas’s goals are to reduce single-family waste landfilled by 45% by 2040; recycle 80% of organic waste and 90% of paper waste by 2050. Dallas’ goal is to divert 60% of recycling, organics and brush by 2025. Phoenix’s goal is to divert 50% of waste from landfills by 2030 and at least 90% by 2050.
Virginia's solid waste and recycling policies and regulations are unclear and in need of specific improvements. DEQ should identify ways to incorporate source reduction into their regulations, and begin this process with the most-littered as well as the most difficult-to-recycle products. The ultimate goal should be an authentic, genuine circular economy, and the agency's plan should be in following with this goal.
Recommendations to the Agency:
The intent of Executive Order 19 (EO19) to reduce regulatory oversight by 25% is arbitrary and will not lead toward meaningful reduction or diversion of waste. EO19 should not serve as a guiding document in the Agency's Periodic Review process or considerations.
Increase and improve upon monitoring and benchmarks.
Measuring waste by weight rather than volume is misleading and inappropriate.
Develop a comprehensive list of recyclables in Virginia.
Improve and increase goals.
Require producers to achieve goals.
Eliminate the greenwashing of recycling.
Thank you for this opportunity to provide public comment. Virginia Conservation Network and our more than 150 Partner organizations look forward to working with DEQ to bring about meaningful and substantive reduction and diversion of wastes while protecting the Commonwealth's environmental and human health.
Recycling is necessary for Virginia to achieve a true circular economy and the continued review of the Solid Waste Planning and Recycling Regulations ensures the regulations are responsive to the evolving needs of the Commonwealth as challenges and opportunities evolve. Solid Waste Planning and Recycling regulations should be a tool to help Virginia create a true circular economy and support recycling programs. As stated by the Environmental Protection Agency (EPA), “A circular economy keeps materials, products, and services in circulation for as long as possible.”
Source reduction is the top priority listed in Virginia’s Planning Requirements Code and as such, Virginia’s regulations should support this priority with the goal of conserving our natural resources and reducing the amount of recyclable materials and waste that goes into landfills. The regulations are a powerful tool to facilitate the most impactful and meaningful solutions pursued by the Commonwealth and communities within.
Unfortunately, communities across the Commonwealth are reducing in size or eliminating their recycling programs due to funding and staff capacity reductions. Improving recycling rates in Virginia will require a financial investment in improved infrastructure but the general public should not shoulder the bulk of this funding burden. Producers and distributors of waste generating products should financially support recycling infrastructure.
Data shared by the Northern Virginia Regional Commission showed that shifting the financial responsibility for recycling infrastructure from the general public to plastic producers and distributors is favored by 84% of local governments. A recent survey from Clean Virginia Waterways showed that 71% of Virginia voters support policies that shift the costs of recycling programs off community taxpayers and onto producers.
Comment 1: Avoid Inconsistencies in Definitions Across Regulations.
Definitions should remain consistent across Virginia codes to avoid confusion and disparate applications among various stakeholders. Changes should only be made to provide additional clarification and ensure consistent and successful application of current rules.
For example, “Advanced recycling” has been clearly defined in Virginia code (§ 10.1-1400) as a manufacturing process. Facilities that use “advanced recycling” processes such as pyrolysis, gasification, depolymerization, reforming, hydrogenation, solvolysis, catalytic cracking, and similar processes for the conversion of post-use polymers and recovered feedstocks into basic hydrocarbon raw materials, feedstocks, chemicals, liquid fuels, waxes, lubricants, or other products should not be included in solid waste planning and recycling regulations because they are regulated as a manufacturing process under § 10.1-1400. If this process was to be defined differently in the Solid Waste Planning and Recycling Regulations than it already is in other regulatory contexts, incongruous enforcement of specific restrictions, oversight, and tax protocols may result in negative outcomes.
The following are opportunities to clarify the current definitions in the Solid Waste Planning and Recycling Regulations.
Recommendation: Throughout the Definitions and other sections, it must be clearly stated that “advanced recycling,” pyrolysis, gasification, depolymerization, reforming, hydrogenation, solvolysis, catalytic cracking, and similar processes when used in the production of plastic-to-fuel, plastic-to-fuel substitute, and plastic-to-fuel additives are not considered recycling, and shall be subject to all applicable federal and state environmental laws and regulations. This is consistent with the U.S. EPA, and several other national policies related to solid waste.
Incineration: Pyrolysis is already defined as incineration (the controlled combustion of solid waste for disposal) in 9VAC5-40-7380. Municipal waste combustion units do not include pyrolysis or combustion units located at a plastics or rubber recycling unit because these units are regulated as part of a manufacturing process, not solid waste.
Recommendation - Clarify here the types of facilities using incineration to include: Any facility using pyrolysis, gasification, depolymerization, reforming, hydrogenation, solvolysis, catalytic cracking, and similar processes.
"Litter" is currently defined as “all waste material disposable packages or containers, but not including the wastes of the primary processes of mining, logging, farming, or manufacturing.” Usually, “Litter” is defined as mis-managed waste or trash that ends up in the environment. Waste items, when correctly disposed of, are not considered “litter”.
Recommendation: Rewrite this definition to be consistent with the EPA and the legal definition of litter. EPA states: “Littering is a type of pollution that occurs when garbage, including plastics, paper, and metal, are not disposed of properly and can enter coastal waters.
Another detailed definition is: “LITTER. Includes any man-made or man-used waste, which, if deposited otherwise than in a waste receptacle, tends to create a danger to public health, safety and welfare or to impair the environment. LITTER shall include, but is not limited to, garbage, trash, refuse, debris, grass clippings or other lawn or garden waste, paper products, glass, metal, plastic or paper containers, motor vehicle parts, furniture, carcasses of dead animals or any other waste material of an unsightly, unsanitary, nauseous or offensive nature.”
“Materials recovery facility" is currently defined as “a facility for the collection, processing, and marketing of recyclable materials including metal, paper, plastics, and glass.”
Recommendation: Clarify this. Facilities using processes defined as “incineration” (9VAC5-40-7380) or “advanced recycling” (§ 10.1-1400) in Virginia code to produce plastic-to-fuel, plastic-to-fuel substitutes, and plastic-to-fuel additives can not be classified as materials recovery facilities.
"Recycling" means the process of separating a given waste material from the waste stream and processing it so that it may be used again as a raw material for a product, which may or may not be similar to the original product. For the purpose of this chapter, recycling shall not include processes that only involve size reduction.
Recommendation: Clarify this. Pyrolysis and other plastics-to-fuel technologies are not to be considered recycling, this will make Virginia consistent with the EPA that states: “Activities that convert non-hazardous solid waste to fuels or fuel substitutes (“plastics-to-fuel”) or for energy production are not considered to be “recycling” activities. (Language is modified from the EPA Draft National Strategy to Prevent Plastic Pollution)
Any processes defined as incineration in Virginia code can not be considered a recycling activity as incineration is listed as the fifth priority in the hierarchy set forth in 9VAC20-130-120 planning requirements.
"Resource recovery system" is currently defined as “a solid waste management system that provides for collection, separation, recycling, and recovery of energy or solid wastes, including disposal of nonrecoverable waste residues.”
Recommendation: Clarify this. Any processes defined as incineration in Virginia code (9VAC5-40-7380) cannot be considered a resource recovery system. Plastic-to-fuel technologies are not resource recovery systems and their classification should be consistent with EPA guidance.
"Source reduction" is defined as “any action that reduces or eliminates the generation of waste at the source, usually within a process. Source reduction measures include process modifications, feedstock substitutions, improvements in feedstock purity, improvements in housekeeping and management practices, increases in the efficiency of machinery, and recycling within a process. Source reduction minimizes the material that must be managed by waste disposal or nondisposal options by creating less waste.” "Source reduction" is also called "waste prevention," "waste minimization," or "waste reduction."
Recommendation: Clarify this. Processes defined as incineration in Virginia code (9VAC5-40-7380) should be specifically excluded from “source reduction” strategies, as incineration is the fifth priority in the hierarchy set forth in 9VAC20-130-120 planning requirements. Source reduction strategies are the first priority.
Plastic-to-fuel technologies should be specifically excluded from “source reduction” strategies as these technologies are classified as a manufacturing process and increase waste production.
Comment 2: Increase the Minimum Recycling Rates and Tailor the Rates by Material
The regulations currently outline minimum recycling rates stating “each solid waste planning unit shall maintain a minimum 25% recycling rate; or each solid waste planning unit shall maintain a minimum 15% recycling rate if it has (i) a population density rate of less than 100 persons per square mile according to the most recent United States Census or (ii) a not seasonally adjusted civilian unemployment rate for the immediately preceding calendar year that is at least 50% greater than the state average as reported by the Virginia Employment Commission for such year.”
There are seventeen Solid Waste Planning Units (SWPU) that are required to report annually. Their reported recycling rates varied from a low of 23.9% to a high of 57.9%. Sixteen of the seventeen SWPUs surpassed the 25% goal, and the seventeen SWPUs averaged 43.30%.
Nineteen Solid Waste Planning Units (SWPU) with populations 100,000 or less voluntarily reported. Their reported recycling rates varied from a low of 17.5% to a high of 63.5%. All of the nineteen reporting SWPUs surpassed the 15% goal.
Recommendation: In the spirit of Executive Order 17, raise the minimum recycling rate to 40% for urban areas (eight of the seventeen annual reporting SWPUs are already surpassing the 40% mark). Implement a ten year mandate for all seventeen of these SWPUs to increase recycling rates to 80%. For rural areas of Virginia, raise the minimum recycling rate to 25%. Implement a ten year mandate for all SWPUs in lower population areas to achieve 60% recycling rates.
Recommendation: Mandate minimum recycling requirements by material: plastic, tires, glass, etc. This can help Virginia and localities develop programs to target specific recycling programs.
Thank you for the opportunity to provide comments as you examine the future of this critical regulatory framework.
Lynnhaven River Now (LRNOW) is a 501(c)(3) organization that for over 20 years has been dedicated to protecting and restoring Virginia Beach’s waterways, which all flow into the Atlantic Ocean. Our diverse and complex waterway systems are significantly impacted by both runoff pollution and plastic pollution, including micro-plastics . In order to address this, one of our main priorities is to reduce plastic consumption in the Hampton Roads region through our public education and outreach efforts that includes engagement with local businesses and decision markers. We also organize monthly waterway cleanups that have removed over 35 tons of trash since 2003, much of which is plastic waste. In 2022 alone, we removed 10,000 pounds of trash and are concerned that the problem is growing due to the expanding demand and widespread use of plastics. According to the International Energy Agency, plastic production is anticipated to double by 2040 and become the biggest growth market for oil demand over the next decade.
While it is worth noting that recycling in the United States has experienced significant cost increases and setbacks due to China's 2018 “National Sword'' policy, (which halted the import of plastics and other materials destined for its recycling processors) we maintain that we need to continue domestic recycling programs and work to improve them in order to help reduce plastic waste in our landfills and oceans. We have outlined key policy recommendations we support to help address some of the cost and logistical hurdles of domestic recycling in the Commonwealth.
Implement extended producer liability for plastic products (EPR).
The financial burden of plastic waste should not entirely fall on the public as it does now.
EPR model is very efficient for reducing waste because producers have the most influence over the design of products and packaging. If they are partially (if wholly) responsible for the cost of recycling or disposal, they will be incentivized to design their products to be more easily recovered and/or disposed of.
The Plastic Waste Makers Index, (developed with partners including Wood Mackenzie, and experts from the London School of Economics and Stockholm Environment Institute among others) has demonstrated that just 20 companies produce over 50% of the world's single use plastic.
Many other industries are required to process their own waste, why should these plastic producers be an exception?
A 2017 survey by the Northern VA Waste Management board found that 84% of local governments indicated that they would like to see manufacturers, distributors and retailers take more responsibility for the management of difficult to handle waste.
Improve transparency around recycling reporting by Solid Waste Planning Units (SWPU)
Under current practices, the actual statistics produced by SWPU do not provide a clear breakdown of what is being recycled or how.
This makes it harder to tackle our recycling issues since we do not have clear data on the actual breakdown of what is collected and processed.
Raise Required Recycling Rates
According to the 2021 VA DEQ Annual Recycling Summary, current required recycling rates are being surpassed by all SWPU. This suggests that we should explore being more ambitious.
Urban areas, where most of the single use plastic is being collected, should observe a minimum of 40% for their recycling rate.
Rural areas should have the rate increased to 25%
This increase will be more achievable once measures are taken to improve SWPU data collection.
Furthermore, we cannot support any policies that would in any way entertain or encourage any type of advanced recycling programs that use dangerous pyrolysis methods which are known to produce hazardous waste such as dioxins and toxic air pollution. VA DEQ already codifies pyrolysis as incineration, not recycling, and the EPA has already affirmed that it does not consider activities that convert non-hazardous solid waste into fuel, fuel substitutes or energy production to be recycling activities. We feel that this categorization is both accurate and appropriate.
In conjunction with the public health concerns posed by pyrolysis, a diverse range of studies on the viability of this process have demonstrated that it is a panacea for our plastic issue. In 2019, a study commissioned by Reynolds Consumer Products and completed by Sustainable Solutions Corporation examined the “Hefty EnergyBag” program which operated in 4 regions in the US (Cobb County, GA; Omaha, NE; Lincoln, NE; and Boise, ID). The study examined the environmental impact of recycling plastic waste through pyrolysis versus two conventional methods of disposal: burning it in cement kilns or landfill. In the Boise case, pyrolysis fared worst in terms of its overall global warming. Another analysis examining the final recycling process and its contribution to global warming, found that "pyrolysis scored better than landfilling but was worse than burning plastic in a cement kiln". Pyrolysis is also known to be both highly energy intensive and inefficient because the energy required to heat plastics and extract chemicals from the waste is more than the energy produced by the chemicals. Therefore, at this point in time, it is a distraction from more viable alternatives and should not be pursued at the Commonwealth's expense or at the expense of the health and safety of its residents.
Thank you for your time and consideration of our recommendations. If need be, we are available for further follow questions.